Personal Data Protection Policy

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Personal Data Protection Policy

The purpose of this data protection policy is to inform you how Tradeline LTD (known as Dressup Group) (I/N: 203827449, address: D. Gamrekeli N19, office N29, contact information: (+995) 032 2 38 48 68; E-mail: [email protected], Personal Data Protection Officer : Tamuna Kemertelidze, tel: +995 32 38 48 98 (0203), E-mail: [email protected]) (also referred as Company) processes and uses the personal data of Customers registered on the website www.dressup.ge, and how it ensures the confidentiality and security of that data.

Tradeline LTD processes the following personal data of Customers registered on www.dressup.ge: first name, last name, personal identification number, gender, phone number, email address, residential address, purchase history, payment operations for purchased products and the last four digits of the credit card used for purchasing the product, if the Customer selects the option to save the card.

The purpose of processing this personal data is to receive and process orders placed by Customers on www.dressup.ge, deliver products to Customers using courier services, handle payments and refunds (including partial refunds), provide necessary equipment and materials for service delivery, conduct Customer satisfaction surveys and prepare reports, accumulate loyalty points for the "Dressup" card (if the Customer holds the card), and detect and investigate fraud and potential crimes against www.dressup.ge and its Customers in accordance with Georgian legislation. Please note that Customer will not be able to benefit from the advantages of the loyalty card without uploading the "Dressup" loyalty card on the website, including the accumulation of loyalty points.

Tradeline LTD uses third-party services as part of its core operations and may need to share Customers' personal data with them to perform specific tasks. These include:

Payment platforms and service providers (relevant banks) to facilitate the deduction of funds from Customer’s account;
Courier service providers to ensure the timely delivery, exchange, or return of products ordered by Customers:

QuickShipper LLC - (I/N: 405547877; Tel: 032 2 502 502; E-mail: [email protected]);
GlovoApp Georgia LLC - (I/N: 402099475; E-mail: [email protected]);
Wolt Georgia LLC – (I/N: 405260042; E-mail: [email protected]);
Information Communication Systems LLC (FedEx) – (I/N: 204885810; Tel: 032 291 02 20; E-mail: [email protected]).

SMS and E-mail service providers - WiFisher LLC (I/N: 400147337, Tel: +995 598185556) to provide Customers with relevant information about the status of their orders:
Specialized companies for the detection, investigation, and prevention of fraud and other types of crimes or violations.

Additionally, data processing should be conducted to the extent necessary to achieve the intended purpose. The transfer of Customers’ personal information to third parties, specifically government, regulatory, and law enforcement authorities, will be carried out in accordance with established legal procedures. Such information may also be transferred in circumstances not explicitly provided for by law, in order to protect legitimate interests.

The list of authorized persons for data processing may be subject to updates, which will be immediately reflected in this policy. The personal data protection policy is available at www.dressup.ge.

Tradeline LTD has implemented the necessary organizational and technical measures to protect personal data under its control from unauthorized access, misuse, disclosure, unauthorized modification, illegal destruction, or accidental loss. All data is secured at a level that supports data integrity and confidentiality. Access to personal data is strictly controlled, and only authorized personnel have access to Customer data, minimizing potential risks. The Company conducts regular monitoring for the security of personal data. A Customer’s personal data will not be disclosed to third parties without the Customer’s prior consent, except as provided by law.

The Customer is entitled, upon request, to receive the following information from Tradeline LTD:

What data is being processed, the purpose of processing, and the legal basis;
Information about the source of data collection;
The retention period of the data, or if that cannot be determined, the criteria used to define it;
Information about the rights of data subjects as defined by the Law of Georgia on Personal Data Protection;
Legal basis and purposes of data transfers (data transfer means sharing personal information, including sharing information with third parties), and appropriate safeguards in place if data is transferred to another country or international organization;
The identity of data recipients (individuals, legal entities, or public institutions receiving the data, excluding the Personal Data Protection Service), including information about the grounds and purpose for data transfer;
About decisions made as a result of automated processing (processing using automated systems (and not human resources)), including profiling (profiling refers to the processing of personal data for the purpose of analyzing and predicting the Customer's preferences, behavior, or interests), and about the logic used to make such decisions and the expected/probable outcome of data processing.

Customers are entitled to:

Access their personal data held by the company and receive free copies, unless:

A fee is required under Georgian law;
The company has established a reasonable fee for providing the data in a different format due to resources used or the frequency of requests.

To exercise this right, please refer to this data protection policy. Customer can request additional information by sending a written request and a copy of their ID to [email protected].

Request correction, update, or completion of inaccurate, incorrect, or incomplete data.

To do this, the Customer must send a written request to [email protected], specifying the data to be corrected/updated and providing accurate information, along with a copy of their ID.

Request termination, deletion, or destruction of data processing, including profiling. The Company may deny this request if:

There are legal grounds for processing under Articles 5 and 6 of the Georgian Law on Personal Data Protection;
Data is needed for a legal claim or defense;
Processing is necessary to exercise freedom of expression or information.

The request must be sent to [email protected], specifying the reason (e.g., withdrawal of consent), with a copy of the Customer’s ID.

Request data blocking, meaning the temporary suspension of processing. This does not affect the right to store the data.

A written request with reasons (e.g., if the Customer contests accuracy, requests deletion, or data is needed for legal purposes) should be sent to [email protected], with a copy of the Customer' ID.

Request data portability, i.e., to receive their provided data in a structured, commonly used, machine-readable format, or to have it transferred to another controller, if technically feasible.

The Customer must send a request to [email protected], specifying the target recipient, along with a copy of their ID.

Not be subject solely to automated decision-making, including profiling, which has legal or significant effects on them, unless:

The decision is based on the Customer’s explicit consent;
It's necessary for a contract between the Customer and the Company;
It's authorized by law.
To exercise this right, the Customer must send a request and ID copy to [email protected].

Withdraw previously given consent at any time, without explanation, using the same method by which consent was given.

A Customer must send a written withdrawal request and a copy of ID to [email protected].

File a complaint with the Personal Data Protection Service, a court, or a higher administrative body if the Company violates the Customer's rights or any legal procedures.

Tradeline LTD operates in accordance with the legislation of Georgia, based on which the Customer may be restricted in exercising the rights to receive, access, and obtain a copy of information regarding personal data processing, to request correction, updating and/or completion, data portability, termination of personal data processing (including profiling and automated individual decision-making), destruction, blocking and/or deletion, and withdrawal of consent.The above-mentioned obligations may derive from: anti-money laundering regulations, Article 129, Paragraph 1 of the Civil Code of Georgia (regarding the statute of limitations for contractual relationships/claims), the Tax Code of Georgia, the Law of Georgia on the Protection of Consumer Rights, the Law of Georgia on Personal Data Protection, and other applicable legal acts.

The Customer is responsible for the accuracy and correctness of the information provided to the Company on www.dressup.ge. The Customer is obligated to correct any personal data provided to the Company if there are any changes. The Company is not liable for damages arising from changes to the Customer's personal data unless the Company is notified of these changes through the updated personal data posted on the website.

Tradeline LTD is not responsible for any damages suffered by Customers due to unauthorized access to the electronic devices through which Customers receive services, resulting in lost or stolen data.

The Customer can request at any time the cessation of processing of their personal data by Tradeline LTD and the cancellation of their account without any justification or explanation. To do so, they must contact the Company through the official chat at the following links: https://www.facebook.com/DressupGroup/?locale=ka_GE or https://www.facebook.com/www.Dressup.ge/. This link is available at the bottom of www.dressup.ge, represented by the Facebook "F" icon above the informational graphics.

Tradeline LTD is obligated to comply with the Customer's request to cease the processing of personal data, except in cases where:

There is a legal basis for data processing as outlined in Articles 5 and 6 of the Georgian Law on Personal Data Processing;
The data is processed for the purpose of substantiating a legal claim or complaint;
The processing of data is necessary for the exercise of the right to freedom of expression or information.

Tradeline LTD processes the Customer's personal data for the entire duration of their Account and continues to process personal data after the Account is canceled, in accordance with applicable law, for no longer than 3 (three) years based on Article 129, Paragraph 1 of the Civil Code of Georgia (regarding the statute of limitations for contractual relationships/claims) and due to the existence of legal obligations for retaining tax records. In the case of any dispute that may be related to the processing of the Customer’s personal data – the data will be retained until the resolution of the respective dispute.

Customer consent to this data protection policy is mandatory during registration on www.dressup.ge. If the Customer refuses to consent, they will have limited access to the site; specifically, they will not be able to register, create an Account or purchase products from the site. However, the Customer retains the right to browse products on www.dressup.ge, view available sizes, and see which branches have them in stock.

This data protection policy may be amended in accordance with legislative changes and/or changes to the Company's personal data protection policy. Tradeline LTD is entitled to make such changes unilaterally, without the Customer's consent. Any changes made to this document will be promptly reflected on www.dressup.ge. Additionally, Customers will be notified of significant changes via SMS. Any changes and/or additions shall enter into force after sending a personal notification to the Customer or after publication on the website. After the changes and additions come into effect, the Customer’s continued use of www.dressup.ge will be considered as agreement to the modified terms.

Data Processing for Direct Marketing Purposes

If the Customer provides consent through an active action for the processing of their data for direct marketing purposes, Tradeline LTD will process the following Customer data for direct marketing: phone number and/or email address.

The authorized person responsible for processing within the Company for the purpose of sending marketing offers is:

WiFisher LLC (I/N: 400147337), Tel: +995 598185556 – for the purpose of sending marketing offers.

The Customer is entitled to withdraw their declared consent for the processing of data for direct marketing purposes at any time by marking the appropriate button in their Personal Account on https://dressup.ge (where they initially provided consent), by sending a message in the official customer support chat on Facebook (link: https://www.facebook.com/www.Dressup.ge/), or by responding to received SMS messages with 'SMS OFF' or using the 'UNSUBSCRIBE' function for marketing offers received via email.

The exercise of the right to withdraw consent through any of the methods specified above is free of charge.

The processing of the Customer’s phone number and/or email for direct marketing purposes is carried out throughout the duration of the Customer’s consent statement, until the Customer decides to withdraw their consent.

According to Personal Data Protection Law of Georgia, the Company is obligated to record and retain the time and fact of the Customer’s consent and withdrawal of consent for the duration of direct marketing activities and for one (1) year after the cessation of direct marketing.

Upon recording the Customer’s withdrawal of consent, the Company will cease the processing of the Customer’s data for direct marketing purposes within a reasonable timeframe, but no later than seven (7) business days from the receipt of the respective request.

The Customer's request to stop receiving marketing messages does not imply that they will not receive informational messages regarding the status of their current orders (if applicable).